L-17-190, Response to Request for Information Regarding License Renewal Commitment No. 54

From kanterella
Jump to navigation Jump to search
Response to Request for Information Regarding License Renewal Commitment No. 54
ML17163A411
Person / Time
Site: Davis Besse Cleveland Electric icon.png
Issue date: 06/08/2017
From: Boles B
FirstEnergy Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
L-17-190
Download: ML17163A411 (6)


Text

WITHHOLD IN ACCORDANCE WITH 10 CFR 2.390(a)(4)

FENOC' WHEN SEPARATED FROM ENCLOSURE C, HANDLE THIS DOCUMENT AS DECONTROLLED 5501 North State Route 2 Oak Harbor, Ohio 43449 RrstEnergy Nuclear Operating Company Brian D. Boles 419-321-7676 Vice President, Nuclear June 8, 2017 L-17-190 10 CFR 50 ATTN: Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555-0001

SUBJECT:

Davis-Besse Nuclear Power Station, Unit No. 1 Docket No. 50-346, License Number NPF-3

  • Response to Request for Information Regarding License Renewal Commitment No. 54 By letter dated January 23, 2017 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML17026A004), as supplemented by letter dated March 23, 2017 (ADAMS Accession No. ML17086A019), the FirstEnergy Nuclear Operating Company (FENOC) submitted an evaluation by AREVA in response to Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS), License Renewal Commitment No.
54. By electronic mail dated May 9, 2017 (ADAMS Accession No. ML17129A411), the U.S. Nuclear Regulatory Commission (NRC) staff determined that additional information was required to complete its review of the submittals.

The Enclosures listed below provide the FENOC response to the Request for Additional Information on Time:--Limited Aging Analysis for the DBNPS Reactor Vessel Internals:

A. AREVA Affidavit to Support the Disclosure Request for the Proprietary AREVA Report AREVA Report ANP-354201 P Revision 0, "Response to NRC Request for Additional Information on Time-Limited Aging Analysis for the DB-1 Reactor Vessel Internals" B. AREVA Report ANP-354201 NP Revision 0, "Response to NRC Request for Additional Information on Time-Limited Aging Analysis for the DB-1 Reactor Vessel Internals" (Non-Proprietary)

C. AREVA Report ANP-354201 P Revision 0, "Response to NRC Request for Additional Information on Time-Limited Aging Analysis for the DB-1 Reactor Vessel Internals" (Proprietary)

AREVA Report ANP-354201 P Revision 0 (Enclosure C) documents DBNPS reactor vessel internals Time-Limited Aging Analysis details that are considered proprietary information that is to be withheld from public disclosure pursuant to 10 CFR2.390. A non-proprietary version of the document is provided as Enclosure B. Upon removal of Enclosure C, this letter can be decontrolled. . . Ir r

)/~/ ..

fl) f-- re--

Davis-Besse Nuclear Power Station, Unit No. 1 L-17-190 Page 2 There are no regulatory commitments contained in this letter. If there are any questions or if additional information is required, please contact Mr. Patrick J. McCloskey, Manager- Regulatory Compliance, at (419) 321-7274.

Sincerely,

~)~

Brian D. Boles

Enclosures:

A. AREVA Affidavit to Support the Disclosure Request for the Proprietary AREVA Report AREVA Report ANP-354201 P Revision 0, "Response to NRC Request for Additional Information on Time-Limited Aging Analysis for the DB-1 Reactor Vessel Internals"

  • B. 'AREVA Report ANP-354201 NP Revision 0, "Response to NRC Request for Additional Information on Time-Limited Aging Analysis for the DB-1 Reactor Vessel Internals" (Non-Proprietary)

C. AREVA Report ANP-354201 P Revision 0, "Response to NRC Request for Additional Information on Time-Limited Aging Analysis for the DB-1 Reactor Vessel Internals" (Proprietary) cc: w/o Enclosures NRC Region Ill Administrator NRR Project Manager NRC Resident Inspector Utility Radiological Safety Board

Enclosure A Letter L-17-190 Davis-Besse Nuclear Power Station, Unit No. 1 (DBNPS)

AREVA Affidavit to Support the Disclosure Request for the Proprietary AREVA Report AREVA Report ANP-354201 P Revision 0, "Response to NRC Request for Additional Information on Time-Limited Aging Analysis for the DB-1 Reactor Vessel Internals" 3 1pages follow

AFFIDAVIT COMMONWEALTH OF VIRGINIA )

) SS.

CITY OF LYNCHBURG )

1. My name is Tom Ryan. I am Manager, Product Licensing, for AREVA Inc.

(AREVA) and as such I am authorized to execute this Affidavit.

2. I am familiar with the criteria applied by AREVA to determine whether certain AREVA information is proprietary. I am familiar with the policies established by AREVA to ensure the proper application of these criteria.
3. I am familiar with the AREVA information contained in the AREVA document "ANP-354201 P, Revision 0, Response to NRC Request for Additional Information on Time-Limited Aging Analysis for the DB-1 Reactor Vessel Internals", and referred to herein as "Document." Information contained in this Document has been classified by AREVA as proprietary in accordance with the policies established by AREVA Inc. for the control and protection of proprietary and confidential information.
4. This Document contains information of a proprietary and confidential nature and is of the type customarily held in confidence by AREVA and not made available to the public.

Based on my experience, I am aware that other companies regard information of the kind contained in this Document as proprietary and confidential.

5. This Document has been made available to the U.S. Nuclear Regulatory Commission in confidence with the request that the information contained in this Document be withheld from public disclosure. The request for withholding of proprietary information is made in accordance with 10 CFR 2.390. The information for which withholding from disclosure is

requested qualifies under 10 CFR 2.390(a)(4) "Trade secrets and commercial or financial information."

6. The following criteria are customarily applied by AREVA to determine whether information should be classified as proprietary:

(a) The information reveals details of AREVA's research and development plans and programs or their results.

(b) Use of the information by a competitor would permit the competitor to significantly reduce its expenditures, in time or resources, to design, produce, or market a similar product or service.

(c) The information includes test data or analytical techniques concerning a process, methodology, or component, the application of which results in a competitive advantage for AREVA.

(d) The information reveals certain distinguishing aspects of a process, method~logy, or component, the exclusive use of which provides a competitive advantage for AREVA in product optimization or marketability.

(e) The information is vital to a competitive advantage held by AREVA, would be helpful to competitors to AREVA, and would likely cause substantial harm to the competitive position of AREVA.

The information in this Document is considered proprietary for the reasons set forth in paragraphs 6(a}, 6(c) and 6(d) above.

7. In accordance with AREVA's policies governing the protection and control of information, proprietary information contained in this Document has been made available, on a limited basis, to others outside AREVA only as required and under suitable agreement providing for nondisclosure and limited use of the information.
8.
  • AREVA policy requires that proprietary information be kept in a secured file or area and distributed on a need-to-know basis.
9. The foregoing statements are true and correct to the best of my knowledge, information, and belief.

SUBSCRIBED before me this day of W\..MJy' I 2017.

Sherry L. McFaden NOTARY PUBLIC, COMMONWEALTH OF VIRGINIA MY COMMISSION EXPIRES: 10/31/18 Reg. # 7079129 SHERRY(. MCFADEN No,1rr*Publlo

  • commonwellth of V1rg1n11 7079129 Mr comm111*1on &xp1r11 ocu1, 20f8